The New York State Department of Taxation and Finance issued an advisory opinion explaining that the petitioner’s Internet-based document transfer subscription plans are not subject to sales and use tax. Because the primary purpose of the transactions is to facilitate the transfer of files over the Internet, the Department concluded that the plans constitute non-taxable “bridging” services rather than taxable sales of prewritten software, even though a limited download of software is involved. N.Y. Advisory Opinion, TSB-A-16(6)S (Feb. 25, 2016).